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SDNY Launches Whistleblower Program Aimed at Curbing Corporate and Public Corruption Crimes

The newly announced whistleblower policy gives certain individuals who promptly and completely cooperate with prosecutors the opportunity to receive a non-prosecution agreement in exchange for their information....more

New SEC Chair Proposes Limiting Rule 10b5-1 Trading Plans, Citing ‘Real Cracks' in SEC Insider Trading Enforcement

The U.S. Securities and Exchange Commission (“SEC”) is considering greatly limiting the affirmative defense that protects corporate executives against SEC prosecutions for insider trading claims when they buy or sell their...more

Foreign Corrupt Practices Act 2017 Year-End Update

2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

Foreign Corrupt Practices Act 2016 Year-End Update

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

Foreign Corrupt Practices Act 2014 Year End Update

Over the course of 2014, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) have continued their aggressive enforcement of the Foreign Corrupt Practices Act (“FCPA”). This has led to critical...more

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